Jackson, Oczaveone ( 2015 )

PD-0964-15 PD-0964-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/24/2015 4:16:45 PM Accepted 7/28/2015 2:07:35 PM ABEL ACOSTA CLERK NO. ______________ IN THE TEXAS COURT OF CRIMINAL APPEALS _______________________________________________________________ OCZAVEONE JACKSON Appellant v. THE STATE OF TEXAS Appellee ________________________________________________________________ FROM THE FIFTH COURT OF APPEALS CAUSE NO. 05-14-00985-CR ON APPEAL FROM CRIMINAL DISTRICT COURT NO. 6 DALLAS COUNTY, TEXAS TRIAL COURT NO. F-1260601-X THE HONORABLE JEANINE HOWARD PRESIDING APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW BRUCE ANTON State Bar No. 01274700 ba@sualaw.com SORRELS, UDASHEN & ANTON 2311 Cedar Springs, Suite 250 Dallas, Texas 75201 July 28, 2015 (214) 468-8100 (office) (214) 468-8104 (fax) Attorney for Appellant 1 COMES NOW, OCZAVEONE JACKSON, Appellant herein, and moves this court to issue an extension of time to file his petition for discretionary review, and in support thereof would show the court as follows: I. The opinion of the Fifth Court of Appeals in cause number 05-14-00985- CR, affirming the convictions, was rendered on June 25, 2015. II. The numbers and style of the case in the District Court is No. F-1260601-X, State of Texas v. Oczaveone Jackson. III. Appellant was convicted of aggravated robbery with a deadly weapon and sentenced to life imprisonment. IV. The present deadline for filing the petition for discretionary review in this matter is July 25, 2015. V. No extensions of time to file the brief were previously requested. VI. The reason for this request is that during the last few weeks counsel has been working on the following: APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW - PAGE 2 1. Petition for Writ of Habeas Corpus and Memorandum in Support in Isaac Soria Lopez v. Brad Livingston, Director, in the United States District Court for the Northern District of Texas - Midland Division. 2. Reply to State’s Response to Application for Writ of Habeas Corpus in Ex Parte Charles Atterbury, case no. W401-80045- 08-HC in the 401st Judicial District Court of Collin County, Texas. 3. Appellant’s Reply Brief in Ex Parte Micah Tutton, case no. 10- 14-00360-CR in the Tenth Court of Appeals of Texas. 4. Appellee’s Petition for Discretionary Review in State of Texas v. Mark Twain Simpson, case no. PD-0599-15 in the Texas Court of Criminal Appeals. 5. Petitioner’s Reply Brief in Robert William Cornwell v. State of Texas, case no. PD-1501-14 in the Texas Court of Criminal Appeals. WHEREFORE, PREMISES CONSIDERED, Appellant requests this court to grant an extension of time to file his petition for discretionary review until August 24, 2015. RESPECTFULLY SUBMITTED, /s/ Bruce Anton BRUCE ANTON Texas State Bar No. 01274700 SORRELS, UDASHEN & ANTON 2311 Cedar Springs #250 Dallas, Texas 75201 (214) 468-8100 (214) 468-8104 (fax) ba@sualaw.com APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW - PAGE 3 CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the above entitled motion for extension of time was electronically served to the Appellate Division of the Dallas County District Attorney’s Office and to the State Prosecuting Attorney on this 24th day of July, 2015. /s/ Bruce Anton BRUCE ANTON APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW - PAGE 4